IF there is a reue CHINES EWALL between Johnson and Swarcz then Swarcz Private Equity (SPE)  is a shareholder and not an insider.

HOWEVER, given that CJ is on teh BOD as a designate of Swarcz then and he is there to ensure that SPE's interests are well represented and he can not properly represent the interests of SPE without getting the plays from the sidelines one needs to assume that more than pubic info is being passed from CJ to SPE

Of course this will all be for the Justice dept to decide should it be determined that SPE sold shares after the time that CJ was informed of thr decision.